Adopted by Council: June 2020
Review Date: Easter Term 2023
Committee Ownership: Council
- Planning Activities
- Safeguarding Risk Assessment
- Induction and Training
- Recruitment & Disclosure & Debarring Service (DBS) Checks
- Arrangements for supporting students under the age of 18
- Raising a concern or allegation of abuse
- Procedure for dealing with suspicions or allegations of abuse
- Relevant College policies
a. The College aims to adopt the highest standards and take all reasonable steps in relation to the safety and welfare of children, young people and adults at risk. From time to time, the College encounters children, young people and adults at risk through its teaching and research activities. However, the majority of engagement will be through recruitment and outreach programmes.
b. We recognise that anyone can be subject to discrimination, harassment and victimisation because of age, culture, disability, sexual orientation, gender reassignment, married or civil partnerships, and religion or belief. Comments and actions that contribute to discrimination, harassment or victimisation are not acceptable and will be challenged.
c. This policy aims to support these activities and to offer assurances to those engaged in the work of the College that, through its implementation, the College seeks to protect children, young people and adults at risk and keep them safe from harm when in contact with the College’s employees, Fellows, volunteers, students or other representatives (whether acting in a paid or unpaid capacity) as listed below under Scope. It is also intended to safeguard the interests of employees, Fellows, volunteers, students and anyone who works on behalf of the College and who comes into contact with children, young people or adults at risk.
d. This policy seeks to:
i. promote and prioritise the safety and wellbeing of everyone, particularly children, young people and adults who may be at risk;
ii. ensure that roles and responsibilities are made clear in respect of safeguarding matters and that an appropriate level of information, training and support is provided to those within the College for whom it is necessary;
iii. offer assurances to staff, students, parents, carers, volunteers and visitors that safeguarding concerns will be dealt with effectively and in a timely manner;
iv. follow safer recruitment processes to prevent the employment or ongoing employment of individuals to work with children, young people or adults at risk where they have been barred by the Disclosure and Barring Service (DBS) or are deemed by the College to pose an unacceptable risk;
v. manage effectively the risks associated with activities and events involving children, young people and adults at risk.
a. The College’s Fellows, employees, workers, volunteers, students, alumnae or anyone working on behalf of the College (in a paid or unpaid capacity) are subject to this policy. This includes external speakers at student events.
b. The policy covers all events and activities organized by those working on behalf of or representing the College, as well as official events and activities organized by its students. Such activities include open days, applicant visits and interviews, the interactions between students and the College nurse or counsellor and visits from members of the public.
c. It is expected that external bodies utilising the College’s premises or facilities for external events will have their own safeguarding policies and procedures in place and will take full responsibility for the safeguarding of individuals involved in any related activities. When working with young people on roll with schools, the Schools Liaison Officer will refer any concerns directly to that school's Designated Safeguarding Lead.
a. Safeguarding (1): arrangements in place to protect children, young people and adults at risk in vulnerable circumstances from abuse or neglect.
b. Child/Children: anyone under the age of 18.
c. Adult at Risk: to any person aged 18 years and over who has needs for care and support and, is experiencing, or is at risk of, abuse and neglect and, as a result of those care needs is unable to protect themselves from either the risk of, or the experience of, abuse or neglect.
d. Abuse: physical, sexual, psychological/emotional, financial/material or professional abuse which can also arise from neglect, including those found in Annex A.
e. Murray Edwards College has assessed and analysed eligibility of all job roles via the DBS tool at www.gov.uk/find-out-dbs-check. Regulated activity in relation to adults at risk (2): activities provided to any adult which, if any adult requires them, will mean that the adult will be considered at risk at that particular time. Any time a person engages in one or more of the activities set out below in relation to any adult, they are deemed to be engaging in regulated activity and that adult is deemed to be at risk at that time (3):
i. Providing health care (whether physical or mental, including palliative) provision by any health care professional who is regulated by General Medical Council, General Dental Council, Nursing and Midwifery Council, Health Professions Council.
ii. Providing psychotherapy and counselling which is related to health care the adult is receiving from, or under the direction or supervision of a health care professional.
iii. Providing first aid, when any person administering it is doing so on behalf of an organization established for the purpose of providing first aid (e.g. Red Cross).
iv. Providing personal care as a result of physical or mental illness, including physical assistance with eating or drinking, going to the toilet, washing, bathing, dressing etc., or supervising, training or providing advice/guidance to an adult to undertake these activities themselves where they cannot make the decision to do so unprompted.
v. Providing social work.
vi. Assisting with general household matters (e.g. managing a person’s money, paying their bills, shopping on their behalf).
vii. Assisting in the conduct of a person’s affairs (e.g. undertaking lasting or enduring power of attorney for an adult under the Mental Capacity Act 2005, being an independent mental health advocate etc.).
viii. Conveying (e.g. driving a person specifically for the purpose of conveying them to and from places to receive care as detailed above).
a. The College Council has overall ownership of this Policy, and may nominate one (or more) of its members to oversee and scrutinise safeguarding arrangements. It is the duty of the Trustees to report notifiable incidents to the Charity Commission.
b. The Senior Tutor is the College’s designated Safeguarding Officer, with the Bursar and Deputy Senior Tutor acting as deputies. As such, he/she takes responsibility for the implementation of the policy and will promote the importance of safeguarding within the College. The responsibilities of the Safeguarding Officer are outlined in Annex C. The Safeguarding Officer may delegate responsibilities as appropriate. Given the complexity of safeguarding matters, it is essential that any concerns are reported to the Safeguarding Officer to ensure that one person has access to all the relevant information. This is particularly important where a number of seemingly minor issues may collectively give rise to a more substantial concern.
c. In the event that a complaint or accusation is made about the Safeguarding Officer, this will be considered independently by the appropriate deputy (or another council member). The event may be referred to social services or the police, if appropriate.
d. Each Head of Department is accountable for the adoption and implementation of this policy and for promoting safeguarding within their Department. Every member of the College must abide by this policy.
a. The College Council delegates responsibility to the Head of Department to retain oversight and documentation of regulated activities within their area and to ensure:
i. appropriate training and supervision is available to those employees, workers, Fellows, volunteers or students engaging in them;
ii. occasions in which those engaged in them will need to work alone in an unsupervised way are documented and minimised; and
iii. that they are appropriately risk assessed; and
iv. that children and adults engaged in regulated activities are given clear information about how, and to whom, they can report any safeguarding concerns.
6. Safeguarding Risk Assessment
a. The College Council delegates responsibility to the Head of Department to ensure:
i. that a safeguarding risk assessment is undertaken for all activities within their area (the assessment should consider how the risks identified can be minimised or eliminated, outline the local processes for reporting concerns, take account of health and safety considerations and record training requirements);
ii. that completed safeguarding risk assessments are made available to employees, Fellows, workers, volunteers or students who are involved in the activity; and
iii. that the implementation and review of actions identified within a safeguarding risk assessment is undertaken in a timely manner.
iv. A template safeguarding risk assessment can be found in Annex D.
a. The College Council delegates responsibility to the Head of Department to:
i. Ensure that any employee, worker, Fellow, volunteer, student or any other representative as outlined in the Scope, who is working on behalf of the College within their area:
a. is made aware of the existence of this policy and asked to familiarize themselves with the contents as part of their induction.
b. completes safeguarding training, together with any additional training that may have been identified by any relevant risk assessment processes Prior to engaging in a regulated activity.
ii. Monitor the safeguarding training undertaken by those working on behalf of the College in their area and provide details to the HR Manager for recording.
A list of those roles which require training is available from the HR Manager.
8. Recruitment and Disclosure and Debarring Service (DBS) checks
a. It is the responsibility of the College Council to agree whether a DBS check is required for a role which is to be recruited to.
b. Appropriate DBS checks will be undertaken as standard via the HR department when recruiting to the roles of: Porter, Admissions Tutor, Schools Liaison Officer, Tutorial Office Manager, Nurse and Counsellor, and any other role that the College Council sees appropriate and as deemed appropriate under legislation. The College will undertake additional pre-employment checks where necessary as part of its safeguarding duty, including checking the accreditation of anyone employed by the College as a healthcare or psychotherapy professional such as a Counsellor or Nurse. References from recent previous employers will also be sought.
c. The Safeguarding Officer may refer someone to the DBS as per the guidance.
9. Arrangements for supporting students under the age of 18
a. The College is not able to take on the authority, rights and responsibilities of parents in relation to their children, and it will not act in loco parentis in relation to students who are under the age of 18 years. However, when admitting a student who will be significantly under the age of 18 when coming in to residence, the College will consider a wide range of issues, including social interaction, provision of tutorial support and supervision as follows.
i. Tutorial support and teaching – the format of tutorial and teaching support when under-18s are involved will seek, insofar as their educational experience would not be compromised, to avoid singleton tutorials or supervisions. It is recognized, however, that one-to-one contact with Tutors, Directors of Studies and Supervisors at meetings may be necessary.
ii. IT – Use of the internet by under-18s for study will be as for all students.
iii. Alcohol and student arranged activities – Access to alcohol by undergraduates under the age of 18 at any activity which is signed off by or known to the College will not be permitted. It is acknowledged that the individual student must also bear responsibility for his or her actions at any event. Safeguarding issues will be covered at the sign-off stage with student organisers. Consideration should be given to any risk posed by students over 18 at these events.
iv. The College Bar – the College has effective systems and practices to counter underage drinking and no student under 18 is permitted to work in the College bar.
v. Liaison with Faculties and Departments – the College will inform/consult with the relevant Faculty or Department as early as possible about any student who will be under the age of 18 who is being admitted so that the University can put appropriate measures in place to meet its safeguarding obligations.
vi. Residential accommodation offered by the College is generally intended for the use of adults and, except in exceptional circumstances, special arrangements are not made for students who are under the age of 18 years.
vii. It will be necessary to investigate whether the Home Office will issue a visa to an overseas student who is significantly under the age of 18.
b. Annex E records the arrangements for any academic events sponsored by the College for persons less than 18 years of age.
c. Annex F records the arrangements for events sponsored by external parties and hosted by the College for persons less than 18 years of age.
10. Raising a concern or allegation of abuse
a. Any person involved in the work of the College (Fellows, employees, workers, volunteers, students or anyone working on behalf of the College in a paid or unpaid capacity) can raise a concern or allegation of abuse directly with the Safeguarding Officer or a deputy.
b. The Safeguarding Officer or the deputy will complete a Safeguarding Concern Form (available from the HR Manager).
c. If a concern or allegation is against the Safeguarding Officer, the President or Vice-President will lead the procedure.
11. Procedure for dealing with suspicions or allegations of abuse
a. Those working with children and engaged in regulated activities may:
- have alleged abuse disclosed to them;
- be concerned about events they have heard or seen;
- or be accused of abusing those in their charge.
Whilst these issues may require very different courses of action, it is essential that the safety and welfare of the child or adult at risk is prioritised.
b. The Safeguarding Officer has responsibility for ensuring that they (or a nominated deputy) are available during normal working hours to respond to allegations without delay, and for procedures to be in place should issue arise outside of normal working hours.
c. In the event there is a risk of immediate serious harm to a child or adult at risk, the emergency services should be contacted via 999 without delay. Anybody can make a referral in these circumstances. The Safeguarding Officer should then be notified of the case.
d. Where a child or adult at risk discloses alleged abuse, or a member of the College suspects abuse which is not deemed to be an emergency, this should be referred immediately to the Safeguarding Officer who will consider what action is required. A referral should be made even where concerns are seemingly minor; in some instances it is a pattern or range of minor incidents which, when taken together, amount to a more significant concern requiring investigation. It is therefore vital that the Safeguarding Officer is privy to all concerns as they arise.
e. Appropriate records will be retained by the Safeguarding Officer in accordance with the College’s Data Protection Policy. Where the matter relates to both staff and students, the Safeguarding Officer will determine where the file should be kept.
f. In consultation with the President and HR Manager the Safeguarding Officer will be responsible for contacting any statutory agencies if necessary . The Safeguarding Officer will also have responsibility for fulfilling any legal obligations to report an individual to the DBS.
g. The College is not expected and should not attempt to investigate suspicions of abuse independently.
h. Where a suspicion needs to be investigated by the relevant authority, it may be necessary for the College to do one or more of the following, as advised by social services or the police:
i. move the victim of an alleged safeguarding breach to a safe place;
ii. suspend the individual(s) about whom an allegation or suspicion has arisen;
iii. prevent the individual(s) about whom an allegation or suspicion has arisen from engaging in any regulated activities.
i. Serious safeguarding breaches may constitute gross misconduct under the College’s disciplinary policy and may lead to summary dismissal.
j. If a concern or allegation is against the Safeguarding Officer, the President or Vice-President will lead the procedure.
This policy should be read in conjunction with the College’s policies, in particular:
- Appropriate Relationships between Fellows, Bye-Fellows, Staff, Postgraduates engaged in teaching and Students
- Harassment and Sexual Misconduct
- Student Complaints Procedure
- General Data Protection Regulations
- Alcohol Misuse
- Drugs Misuse
- Equal Opportunities
- Health and Safety
- Freedom of Speech
- Online Safeguarding
(1) See Care Act 2014
(2) Full definitions of regulated activity in relation to adults
(3) The roles of the College’s nurse or counsellor are considered to involve engaging in regulated activity with adults. The roles of the College’s academic Senior Tutor, Tutors, Directors of Studies and Supervisors are not considered to involve engaging in regulated activity with adults as defined by the relevant legislation.
Annex B: Guidance for those acting on behalf of the College carrying out activities involving children or adults at risk
Annex C: Role of Safeguarding Officer
Annex D: Safeguarding Risk Assessment Form
Annex E: Arrangements for events sponsored by the college for persons less than 18 years of age
Annex F: Arrangements for events hosted by the college but sponsored by external parties involving persons less than 18 years of age or adults at risk